JEITA Responsible Minerals Online Briefing

Responsible Minerals Online Briefing
June 2020
Japan Electronics and Information Technology
Industries Association (JEITA)
Responsible Minerals Trade Working Group【Notice】
This document was created by the JEITA Responsible Minerals Trade Working Group.
We endeavour to ensure that our information is as recent and accurate as possible, but please beaware that this will not always be the case.

1

Agenda Responsible Minerals Trade - Background－New risks and new minerals－Global impact－New trends
 Due diligence by downstream companies
 Major template changes in 2020 (CMRT/CRT)
Annex: Good Practice Guidelines on Conducting Third Party Due Diligence

2

JEITA ProfileJEITA (Japan Electronics and Information Technology Industries Association)
 385 companies and/or organizations

Our vision
Become a platform
connecting theelectronic equipment,
electronic
components anddevices, and IT
solutions and service
industries

Our work
on conflict mineral issues
 Work launched in 2012
 We encourage supply chains not
to use conflict minerals that
contribute to human rights
violations
 We cooperate with relatedindustries such as automotive
OEM and related governments.
3

Accelerated initiatives toward responsible mineral sourcing

3. Dealing with new risks/minerals
・Conflict-Affected and High-Risk areas
・Annex Ⅱ risks (OECD DD Guidance)
・Cobalt survey

2021
EU Conflict
Minerals
Regulation

2. Conflict Mineral Management
・Define guidelines
・Due diligence (DD)・Take DD-based corrective measures

2011
OECD Due
Diligence
Guidance

1. Identify and report on smelters
・Survey 3TG・Report CMRT to upstream companies
・Disclose to downstream companies

42010
US Dodd-FrankAct

Expand scope of responsible
minerals to include ESG

Deamand for supply chain transparency

4. Expanded risk and mineral scope
・Review of EU regulations (2023)
・Expansion of risk scope to ESG
・Mica trends

Responsible Mineral Sourcing“From a CSR perspective, we do not use minerals
implicated in human rights violations”
Areas addressed
ESG Risks(3TG+コバルト/CAHRAs/Annex Ⅱ)

Responsible Minerals

RMAP(3TG+cobalt/CAHRAs/Annex Ⅱ)（

CMRT/CRT

Conflict Minerals

Future CSR (ESG risks/Business & humanrights) Prepare for mandatory disclosure
to ensure supply chain transparency

As of 2020
 Efforts within RMAP scope
3TG+cobalt/CAHRAs/Annex Ⅱ）(3TG/DRC+9/Conflict)

To date Based on US Dodd-Frank Act
3TG/DRC+9/Involvement in conflict5

Global trends surrounding responsible mineral sourcing
2000
UN Global
Compact（2000）“Soft”
Laws

2010
Principles for
Responsible
Investment（PRI）(2006）

2015
Sustainable
Development Goals(2015)UN Guiding Principles
on Business and Human
Rights（2011）

ISO26000 Guidance on
Social Responsibility（2010）
OECD Guidelines
for Multinational
Enterprises Revision（2000）

OECD DDG*（1st version）
2011

ISO20400 Guidance for
Sustainable Procurement（2017）OECD
Guidance
Revision（2011）

OECD Due Diligence Guidance
For Responsible Business Conduct（2018）

OECD DDG*（2nd version）
2013

OECD DDG*（3rd version）
2016

RMI/GRI
Responsible Report
Tool Kit
2019＊DDG:Due Diligence Guidance for Responsible Minerals

Conflict Minerals
Guidance（EU）
2017

Dodd-Frank Act
（US）
2010
2012 Reviewed

Non-Financial
Reporting Directive,
Directive（EU）“Hard”
Laws

2014

Modern Slavery
Act （UK）
2015

6

Human Rights Due
Diligence Law（France）
2017

Modern Slavery Act（Australia）
2019Why the call for responsible mineral procurement?
Investors

Global Supply Chain
Bribery
Conflicts

MoneylaunderingTaxevasion

Human rights
violations

Tort

Shareholders

ESG investment
ESG investment
Negative screening Lender selection

Avoidance of
direct & indirect
supportMaterial
Suppliers

Financial
Sectors

Equipment

Suppliers

SustainablegrowthBoycotts
Ethical consumption

Downstream
Enterprises

Accusations
Investigations,
audits, conditions

Consumers

Media
NGOs

Advocacy

B2B
・Hard laws (domestic laws)
Customers
・Public tender conditions
・Soft laws (guidelines)
・International standards（ISO26000/20400）
Governments

Laws & regulations +stakeholder pressure trigger
DD

Int’l institutions(UN,OECD)

7International
agreements/
guidelines

US Wall Street Reform and Consumer Protection Act （Dodd-Frank Act）


In the Democratic Republic of the Congo(DRC) and nine neighboring countries, thehuman rights violations and environmental
destruction, etc. caused by armed groups
funded by illegally mined mineral resources
became an international problem.
In July 2010, Article 1502 wasconsequently added to the US Wall Street
Reform and Consumer Protection Act (the"Dodd-Frank Act").
① Tantalum, tin, tungsten, gold (3TG)
defined as conflict minerals② US listed companies subject to thelaw required to investigate
whether the conflict minerals used intheir own products are providing thatfunding and disclose this the following
year.



The final implementation rules wereadopted in August 2012, and conflictminerals surveys began in earnest in 2013.

DRC① South Sudan② Uganda③ Rwanda④ Burundi⑤ Tanzania⑥ Zambia⑦ Angora⑧ Congo⑨ Central Africa

1

9

2
3

8

4
7

6

5

 The Financial Choice Act, which includes theabolition of Article 1502, was drafted after
President Trump took office but has not yet
passed the Senate, leaving the US Dodd-FrankAct still in force.
Seven years have passed since surveys started,with the required accuracy and level of
responses continuing to rise.

8

EU Conflict Minerals Regulation (compared to US DFA)US Dodd-Frank Act (DFA)EU Conflict Minerals Regulation

Effective
Date

July 2010 Establishment
Aug. 2012 Enforcement of SEC rules

July 2017 Establishment
Jan. 2021 Fully applicable（DD responsibility）

TargetUS listed manufacturers

Risk-

Does the mineral fund armed groups?

MineralsTin, tantalum, tungsten, gold

Tin, tantalum, tungsten, gold

Areas

DRC + surrounding 9 countries

Conflict-Affected and High-Risk Areas（CAHRAs)

To doProspect

Importers of minerals to EU＊ Excludes parts and product importers
OECD ANNEX II based（Human rights violations, including child labor）

１．Search 3TG use
２．Supply chain DD
３．Submit annual report

１．Supply chain DD
２．Submit annual report
３．Ex post factor review by EU members

DFA still VALID

2020 CAHRAs list open to public
2020 Transparency platform open to public
2020 Responsible smelter list open to public●EU Regulation: Limited direct impact on Japanese enterprises* Companies with their own base/local entity in the EU should check the tariff (CN) code and threshold in EU Regulation Annex I in
advance.

●The release of a transparency platform for downstream companies may stimulate DD for European downstream companies●The EU plans to review the rules in 2023. At that time,, additional minerals and making DD mandatory for downstream

companies may be considered.

9（Ref）EU Conflict Minerals Regulation –Target Mineral List
Part B: Metals（cont.)

Part A: Minerals
Description

CN codeTARIC
Volume threshold
subdivision(kg)

Tin ores and concentrates

2609 00 00

5 000

Tungsten ores and concentrates

2611 00 00

250 000

Tantalum or niobium ores andconcentrates

ex 2615 90 00 10※Article 1(4) and
Article 18 apply

Gold ores and concentrate

ex 2616 90 00 10※Article 1(4) and
Article 18 apply

Gold, unwrought or in semimanufactured forms, or in powder
with a gold concentration lower
than 99,5 % that has not passed therefining stage

100

Part B: Metals
Description
Tungsten oxides and hydroxides
Tin oxides and hydroxides

CN codeTARIC
subdivision2825 90 40
ex 2825 90 85

Volume threshold(kg)
100 000

10※Article 1(4) and
Article 18 apply

Tin chlorides

2827 39 10

10 000Tungstates

2841 80 00

100 000

Tantalates

ex 2841 90 85

Carbides of tungsten
Carbides of tantalum
Tantalum, unwrought including bars
and rods, obtained simply bysintering; powders

302849 90 30
ex 2849 90 50
8103 20 00※Article 1(4) and
Article 18 apply
10 00010※Article 1(4) and
Article 18 apply
2 500

Volume threshold(kg)

CN codeGold, unwrought or in semimanufactured forms, or in powder
form with a gold concentration of 99,5% or higher that has passed therefining stage

ex 7108 ( )100

Ferrotungsten and ferro-silicotungsten

7202 80 00

25 0008001

100 000

8003 00 00

1 400

Tin, other articles

8007 00

2 100

Tungsten, powders

8101 10 00

2 500

Tungsten, unwrought, including bars
and rods obtained simply by sintering

8101 94 00

500

Tungsten wire

8101 96 00

250

Tungsten bars and rods, other thanthose obtained simply by sintering,profiles, plates, sheets, strip and foil,
and other

8101 99

350

Tantalum, unwrought including bars
and rods, obtained simply by sintering;
powders

8103 20 00

2 500

Tantalum bars and rods, other thanthose obtained simply by sintering,profiles, wire, plates, sheets, strip andfoil, and other8103 90

150

Tin, unwrought
Tin bars, rods, profiles and wires*1

ex 7108 ( )TARIC
subdivision

Description*2※Threshold will be set within the range not less than 95% of the total import
volume by April to July 2020.
(*1) (*2) For the purpose of amending this threshold, the imported volume
obtained by applying the methodology and criteria of Article 18 shall be set
as the threshold for both ex 7108 tariff lines included in Annex I.

10

EU Conflict Minerals Regulations – Conflict-Affected and High-Risk Areas

Definition in OECD DD Guidance Annex II

Conflict-affected and high-risk areas (CAHRAs) are identified by the presence or absence of armed
conflict, widespread violence, or other risks that could harm people.
Armed conflict can take many forms, including international or non-international conflict. It caninvolve two or more countries, or it can be a war of liberation, a rebellion, or a civil war.
High-risk areas include areas with political instability, oppression, institutional shortcomings, andinstability, areas where domestic infrastructure has collapsed, and areas where violence iswidespread. There are widespread human rights abuses and violations of national or internationallaw in these areas.

Definition in EU Conflict Minerals Regulation（applied to CMRT)
Areas in a state of armed conflict, fragile post-conflict areas, as well as areas witnessing weak or
non-existing governance and security, such as failed states, and widespread and systematic
violations of international law, including human rights abuses.

 RMI defines the minimum range of CAHRAs as “DRC+9 countries” and“EU CAHRAs”.
 Finally, enterprises should engage in DD with reference to the following
information sources.
EU non-binding guidelines which identify CAHRAs
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018H1149

 RMI website information designed to help identify CAHRAs
http://www.responsiblemineralsinitiative.org/minerals-due-diligence/risk-management/conflict-affected-and-high-risk-areas/EU to publish a CAHRA list open to the public by Dec. 202011

（Sample）High-Risk
Areas
責任ある鉱物調達対応の背景１
As of May 2020
Conflict
In DRCWorld
WideTerrorism
Child Labor
Forced Labor
Human Rights
Environment
Disruption

Source: Heidelberg Conflict Barometer 2019https://hiik.de/conflict-barometer/current-version/?lang=en

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EU Conflict Minerals Regulation – OECD Annex Ⅱ Risk
From “Conflict in DRC+9 Countries”
to “OECD Annex Ⅱ Risk in CAHRAs”
OECD DD Guidance Annex Ⅱ
Model Supply Chain Policy for Responsible Global Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas
1. Serious abuses associated with the extraction, transport or
trade of minerals (child labor, etc.)
2. Direct or indirect support to non-state armed groups
3. Public or private security forces
4. Bribery and fraudulent representation of the origin ofminerals
5. Money laundering
6. Payment of taxes, fees, and royalties due to governments
13

EU Conflict Minerals Regulation: Transparency platform for downstream companies

•
•
•
•
•
•

Name
Responsible Minerals Information System (ReMIS)
Target Minerals ３TG and others (cobalt, etc.)
Language
English and EU official languages
Registration Voluntary
Content
Company type (upstream/downstream), sectors,
minerals, and supply chain schemes, inclusion/exclusionfrom regulation scope, DD policy and implementation status
Target members
Personnel and enterprises within the EU（Each EU member country to check validity）

Japanese companies may receive more survey requests from
European downstream companies wishing to disclose their DD
status on the platform.
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US regulations affecting RMAP
◎OFAC (Office of Foreign Asset Control) regulations
 For foreign policy and security purposes, OFAC has instituted

regulations banning direct and indirect transactions with countries
or regions and specific individuals or groups designated by the US
and frozen their assets.
Target areas/countries:

Iran, North Korea, Syria, Cuba, Ukraine (Crimea) and multiple
individuals (Sudan and Myanmar may be phased off the list)
OFAC has published the SDN list on its website.
https://www.treasury.gov/resource-center/sanctions/sdn-list/pages/default.aspx

OFAC regulations identified as the scope of risks that smelters
should monitor under new RMAP auditing standards(applicable from January 2019)15

Moves to expand audits to other materials■RMI: Audit program for mica processing facilities together with the
Responsible Mica Initiative

Considering including environmental, social and governance (ESG) areas in auditing
standards along with OECD Guidance Annex II risks. Pilot audits to take place Aug-Dec 2020.

■OECD: Portal for Supply Chain Risk Information

https://www.oecd.org/daf/inv/mne/oecd-portal-for-supply-chain-risk-information.htm

Provides risk information to support Steps 1 and 2 of the Guidance （TBD）
Provides information on supply chains, national risk, and mineral risk
Covers 38 materials■RMI & Drive Sustainability: “Material Change”

https://drivesustainability.org/wp-content/uploads/2018/07/Material-Change_VF.pdf

 Research report aimed at enabling peers and investors to discuss responsible sourcing bycomparing environmental, social and governance issues in materials and producing countries.
 37 materials: Aluminum, nickel, copper, glass, rubber, iron, lithium, mica, zinc, leather, etc.

 Interest in targeted raw materials grows along with methods ofdealing with theseInvestors increasingly expect enterprises to disclose information(ESG investment)
16Moves to expand targeted risks
RRA (Risk Readiness Assessment)

Voluntary self-assessment and self-reporting tool for minerals and metals producers and processors tocommunicate their environmental, social and governance practices and performance.
Objective: To promote a common understanding of good practices and a means to consistently assess
risks and actions to manage risks in the mineral supply chain.

Materials (22 Categories)
Aluminum, alumina, bauxite, cobalt, copper, gold, graphite, iron ore, lead, lithium, mica,
molybdenum, nickel, palladium, platinum, rare earth elements, silver, steel, tantalum, tin,tungsten, zinc
Risk areas and Standards（32 Items）
1. Legal Compliance
2. Business Integrity
3. Stakeholder Engagement
4. Business Relationships
5. Child Labor
6. Forced Labor
7. Freedom of Association andCollective Bargaining
8. Discrimination and Harassment
9. Gender Equality
10. Working Hours
11. Remuneration

12. Occupational Health and Safety
13. Employee Grievance Mechanism
14. Environmental Risk Management
15. Greenhouse Gas (GHG) Emissions
16. Energy Consumption
17. Fresh Water Management andConservation
18. Waste Management
19. Tailings Management
20. Pollution
21. Biodiversity and Protected Areas
22. Mine Closure and Reclamation

23. Community Health and Safety
24. Community Development
25. Artisanal and Small Scale Mining
26. Human Rights
27. Security and Human Rights
28. Indigenous Peoples Rights
29. Land acquisition and resettlement
30. Cultural Heritage
31. Due Diligence in Mineral Supply
Chains
32. Transparency and Disclosure

In future, both minerals and risks could expand even further.
17

Mega Trends
Other ESG risks
Environmental
destruction
E
S
G
R
I
S
K

Human rights (forchildren)

EU regulations
Bolivia

Funding for armed
groups (other than DRC
and surrounding
countries)
Funding for armed
groups (DRC andsurrounding countries)

DRC

Myanmar

DRC

DRC

DRC

DRC

NGO surveys in India
and Madagascar

RMAP Audit Protocol
 Annex Ⅱ Risk
 CAHRAs OFAC

Dodd Frank Act

ESG RISKGold

Tin

Tantalum

Tungsten

Expanding

MATERIALS

CobaltMica

Graphite・・・・

Minerals, areas and risks that companies need to consider in the context of
responsible mineral sourcing will continue to expand

18

International initiatives by downstream companies
RBA (Responsible Business Alliance)
http://www.responsiblebusiness.org/

Promotes CSR in global supply chains
Membership comprises over 150 companies from the electric, automobile
and retail industries
RBA Code of Conduct formulated and announced
Japanese members (as of April 2020)
Brother Industries, Canon, EIZO, Fujitsu, Funai Electric, Konica Minolta,
Nikon, Ricoh, Seiko Epson, Senju Metals, Sony, Sumitomo Electric, Tokyo
Electron, Toshiba, TDK

RMI（Responsible Minerals Initiative）
http://www.responsiblemineralsinitiative.org/

A sub-organization of RBA and one of the most utilized and respectedresources for companies in various industries working on responsible mineralsourcing issues in their supply chains
Formulates and publishes CMRT and CRT forms; formulates RMAP auditing
standards
Many Japanese members; JEITA as Association Member

19Responsible Minerals Assurance Process (RMAP)
Upstream

Range of suppliers

RMAP audit
program

Mines
Traders

Parts
manufacturers
Downstream

Audit

In the long supply chain hierarchy, thenumber of smelters is divided into twotiers to improve survey efficiency.
・ From smelters upstream, smelters areaudited through the RMAP program in
the region to determine the origin of
smelted minerals
・ From smelters downstream, the CMRT
is used to streamline surveys.

Standard

Materials
manufacturers

RMAP Investigation

template

Smelters

・ Vast cost and time forcompanies to audit eachsmelter.

Product manufacturers

RMAP（Responsible Minerals Assurance Process）
CMRT（Conflict Minerals Reporting Template）

Standards revised to ensure that the audit program covers
3TG/CAHRAs/Annex Ⅱ risks

20New RMAP audit protocol expands target risks
Full application of RMAP's new audit protocol from January 2019http://www.responsiblemineralsinitiative.org/standards-development/audit-standards/“Conflict risk in DRC and neighboring countries”
 “OECD Annex II risks in CAHRAs”
OECD DD Guidance Annex II

Model Supply Chain Policy for Responsible Global Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas

1. Serious abuses associated with the extraction, transport or trade ofminerals (child labor, etc.)
2. Direct or indirect support to non-state armed groups
3. Public or private security forces
4. Bribery and fraudulent representation of the origin of minerals
5. Money laundering
6. Payment of taxes, fees, and royalties due to governments
21

Due Diligence
Due Diligence⇒ Risk Assessment (for supply chain transparency)⇒ Make the supply chain transparent and confirm whether the origin of raw

materials presents issues and, should such issues be found to exist, take action to
redress themOECD Due Diligence Guideline
OECD Due Diligence Guidance for Responsible Supply Chains ofMinerals from Conflict-Affected and High-Risk Areas［Background］
Created to help companies respect human rights and avoid
contributing to conflict through their mineral sourcing practices,
including the selection of suppliers

22Due Diligence Five-Step Framework• Step 1: Establish strong company management

systems.
• Step 2: Identify and assess risks in the supply chain.
• Step 3: Design and implement a strategy to mitigate to
identified risks.
• Step 4: Carry out independent third-party audit of key
control points in the supply chain• Step 5: Report annually on supply chain due diligence23

The OECD DD Five Steps
5 Steps in OECD Due
Diligence Guidance

To do

Step 1:
Establish strong company
management systems

・ Adopt due-diligence policies and communicate these inside and outside
the company
・ Create a DD organization chart (clarify leaders and responsible
personnel)
・ Strengthen cooperation with suppliers・ Keep CMRT/CRT (or communication) records for at least five years
・ Communicate company expectations (conformance, etc.) whenrequesting a survey

Step 2:
Identify and assess risks inthe supply chain

・ Conduct a supplier survey using CMRT/CRT・ Clarify procedure for confirming the received CMRT/CRT (riskdetection/identification)

Step 3:
Design and implement a
strategy to respond to
identified risks

・ Consider and implement measures to mitigate and reduce risk

Step 4:
Carry out independent
third-party audit of key
control points in the supply
chain

・ Utilize RMAP audit results
・ Encourage smelters to participate in RMAP (implement through theindustry)

Step 5:
Report annually on supply
chain due diligence・ Report voluntary DD status in CSR reports and on company website

24

2020 Survey Highlights●CMRT Rev.5.12（Apr. 26, 2019）⇒ Rev.6.01*（Latest as of May 19, 2020）⇒ Responds to revisions such as the addition of Q4 on CAHRAs; inaddition to the US Dodd-Frank Act, also corresponds to EU regulations.
* Rev.6.0 initially issued on May 13, 2020 but revised immediately due to a bug
Where the answer to Q4 on the declaration worksheet is "Yes", consideration needs
to be given to ways of identifying those smelters/refiners whose country of origin are
CAHRAs and what country was determined to be CAHRAs (outside of the DRC+9).
(E.g.., by entering the CID number in the comment column or using the O column in the smelter list, etc.)

 The in-house aggregation method in Q4 needs to be reviewed.
 Review of answers to questions A to H (CAHRAs, responsible mineralsourcing policy, etc.)●CRT Rev.1.1 (Dec. 21, 2018）⇒ Rev.2.11* (Latest as of May 19, 2020）⇒ Only partial changes in the wording of Question F, updates to thesmelter list, and some bug fixes. No major impact.

* Rev.2.1 initially issued on May 13, 2020 but revised immediately due to a bug

25

2020 Survey Highlights: Changes in CMRT Rev.6.01
Rev.6.01 features the following changes.
In the company information in the declaration worksheet, the phone number of theperson responsible for the contents of the declaration information is now optionalrather than mandatory.

“Do any of the smelters in your supply chain source the 3TG from conflict-affected andhigh-risk areas? Added as Question 4. (Subsequent numbers are moved down one.)

Question A has been changed to “responsible minerals sourcing policy".

Only the English text of Question B of Declaration has been changed to "responsible
minerals".



Question C has been removed. (Subsequent letters are moved up one.)

Question E becomes D and becomes "due diligence measures for responsible sourcing".

Question I becomes H, "to SEC" has been deleted, and the options have been changed
so that SEC and EU can be selected.

26

2020 Survey Highlights: Changes in CMRT Rev.6.01
CMRT6.0 Declaration sheet comparison table ※＜OPTION＞
section

CMRT5.12

CMRT6.01

Company
Information

Telephone number of the person responsible forthe contents of the declaration information (*)

Telephone number of the person responsible forthe contents of the declaration information

From mandatory to optional－

Do any of the smelters in your supply chain have3TG origins in conflict areas and high-riskareas?(*)<Yes, No or Unknown>

Question added due to EU
regulation compliance

Q4

Explanation

Question A

Have you finalized your conflict mineralprocurement policy?(*)<Yes or No>

Have you established a responsible mineralprocurement policy?(*)<Yes or No>

Question changed due to EU
regulation compliance

Question B

Can your conflict minerals sourcing policy beseen in your website? (*)<Yes or No>

Can your responsible minerals sourcing policy beseen in your website? (*)<Yes or No>

Question changed due to EU
regulation compliance

Question C→abolishedDo you require your primary supplier to be DRC
conflict free? (*) <Yes or No>

Question
H→G

Do you implement due diligence measures forconflict-free mineral procurement? (*)<Yes or No>

Do you implement due diligence measures forresponsible mineral sourcing? (*)<Yes or No>

Question changed due to EU
regulation compliance

Question
I→H

Do you need to submit the Conflict Minerals
Disclosure Information to the SEC once a
year?(*)<Yes or No>

Does your company need to submit disclosure
information on conflict minerals once a year?(*)<"Yes, with the SEC", "Yes, with the EU", "Yes,with the SEC and EU" or "No">Question and options changed
due to EU regulation
compliance－27

Question abolished due to EU
regulations

2020 Survey Highlights: Changes in CRT2.11
Rev.1.1 (Published Dec. 21, 2018)→ Rev.2.0 (Published Oct 30, 2019)➔ Rev.2.11* (Published May 19, 2020; latest version)* Rev.2.1 was initially issued on May 13, 2020 but revised immediately due to a bug.

Changes since Rev.1.1 are only the wording correction in Question F,a smelter list update, and some bug fixes.
 The bug on line 57 of Checker in CRT Rev.1.1 has been fixed.
 You can safely ignore the following bugs that remain in the CRT Rev.2.11
version.
・The Checker's Product List (line 56) is highlighted in red when "A. Company" isselected in the Declaration's "Declaration Range or Class".
・ When “Smelter not yet identified” is selected for Smelter List Column C:
Smelter Look-up
Column D: Smelter name will gray out
Column E: Smelter country will remain blank(According to the instructions, Columns D an E will autopopulate to say“unknown.")
Rev.2.11 can be drawn up in the same way as Rev.1.1.
The next revision is scheduled for fall 2020.

28

Reference: ECAP（Extended Corrective Action Plan）
What is ECAP?
Companies on the Extended Corrective Action Plan (ECAP) list on the RMI website (URL
shown below) are non-conformant to RMAP standards, as determined by their recent
RMAP independent third-party assessment, but have committed to address outstanding
issues going forward and are working on these.
http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/extended-corrective-action-plan/* While a company may be temporarily removed from the conformant list and you may be asked by acustomer to remove them from your supply chain, please note that they may be subsequently restored
to the list.
*Two companies were temporarily placed on this list in 2019 but subsequently restored to theconformant list.

Please check the ECAP list as well as the
Conformant/Active list when checking smelters
29

Summary

4. Expanded risk scope
Mandatory disclosure

３. Dealing withnew risks

2. Conflict mineralmanagement system

１. Identify and report on
smelters★ Future risk preparation★ Responding to CAHRAs/
Annex Ⅱ Risk/3TG+Cobalt★ Ongoing DD improvement★ Greater accuracy in survey
responses

30